September is National Preparedness Month, an annual event to raise awareness about the importance of preparing for emergencies and disasters. The 2024 theme is “Start a Conversation.” Talking about things like emergencies and disasters isn’t always easy, at home or in the workplace. During the month of September, we’re going to be featuring blogs on several topics related to emergency preparedness to help get the conversation started at your organization. Our first blog in this series focuses on the importance of a comprehensive and current Emergency Action Plan and training employees on it.
Emergency Action Plans, also known as Emergency Response Plans (or Contingency Plans for Large Quantity Generators of hazardous waste) are required by the US Occupational Safety and Health Administration (OSHA) in 29 CFR 1910.38. Depending on your facility’s location, there may also be state and/or local requirements for Emergency Action Plans, such as in the Massachusetts Comprehensive Fire Code [527 CMR 1.0] and the New York City Fire Code [FC404.2.1].
Per OSHA, in addition to including emergency contact information, the Emergency Action Plan is required to contain, at a minimum, procedures for the following:
- Reporting a fire or other emergency
- Emergency evacuation, including the type of evacuation (e.g., high-rise buildings) and exit route assignments
- Evacuation of employees who remain to address critical operations before exiting the facility
- Accounting for employees afterward
- Employees performing rescue or medical duties.
The Plan developed for your site also needs to address the types of hazardous materials present and site-specific operations. As recommended by FEMA, the Plan should include procedures related to potential hazards and threats such as:
- Medical and fire emergencies
- Chemical, biological, and radiological spills and releases (depending on site hazards)
- Natural disasters (e.g., hurricanes, tornadoes, earthquakes)
- Workplace violence
- Bomb threats and suspicious packages
- Pandemic preparedness.
Depending on site-specific operations, it may also be necessary to include other topics such as structural collapse, entrapment (e.g., from confined space entry), electrical emergencies, and transportation incidents.
As emphasized by FEMA on their Employee Training website, training is essential to ensure that everyone knows what to do when there is an emergency. Would your employees know how to respond if there were a fire in the building? Do they know who is in charge during an emergency? Do they know who is authorized to speak with the news media? Can they carry out their assigned responsibilities during an emergency?
As part of emergency response training, it’s a good practice to hold drills for the various emergency situations that could arise at your site. Fire drills are recommended at least annually. In addition, holding mock spill training is a great way to enforce proper spill response procedures. It’s nearly impossible to predict how individuals will respond in a true emergency situation, so providing an opportunity to practice is key to successful planning.
Remember, it’s important to keep your Plan current! The Emergency Action Plan (or Contingency Plan) must be updated as the regulations or processes change, or the organization grows. Any major modifications, such as a newly designated Emergency Coordinator, or relocation of the rally point, should be incorporated when they take place. Also consider less obvious reasons for updating the Plan including the introduction of new hazards to the facility, changes in chemical or biological use resulting in increased spill potential, or adjustments to waste storage locations.
In addition, if any part of the written Plan fails in an emergency, it must be reviewed and revised to reflect the appropriate response measures. Retraining is required by OSHA when the Plan is changed and/or when employee’s responsibilities outlined in it are modified.
For additional information on National Preparedness Month, or for assistance with developing, updating, or training on your facility’s Emergency Action Plan or Contingency Plan, please contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training
